FULWELL ENTERTAINMENT, LLC - PRIVACY POLICY

Effective Date: February 25, 2025

1. Introduction

Welcome. You have arrived at a website provided by Fulwell Entertainment, LLC (“Fulwell,” “we,” “our” or “us”).

At Fulwell, we take your privacy seriously. We provide this Privacy Policy (“Policy”) to tell you what information we collect about you, how we obtain it, how we share it, and how you may limit the ways in which we use your Personal Information. If you have questions about this Policy after you review it, feel free to contact us at privacy@fulwell.com.

2. Scope

This Policy governs www.fulwell.com, www.uninterrupted.com, www.therobotco.com, www.makespringhill.com, their subdomains, and all subdomains or portals that link to this Policy (“Sites”); or otherwise provide Personal Information or interact with us online or in-person.

“Personal information” means any Personal Information relating to an identified or identifiable individual that is protected by applicable privacy laws. We refer to all the above as our “Services.” Our Services are used by our business partners (“Partners”), individuals who visit the Sites or shop at our online store (“Visitors”) and individuals seeking employment with us (“Employment Applicants”).

By using our Sites or Services, you consent to this Policy and agree to our Terms of Use.

3. What Information We Collect

As a rule, we limit the Personal Information we collect to that which is adequate, relevant and reasonably necessary for us to provide our Services to you.

Information You Provide to Us

As you interact with our Sites or Services, we collect the following Personal Information via online webforms or inputs/uploads on our Sites, and through telephone calls, text messages, letters, emails and other communications with you.

Visitors

  • Contact information such as your first and last name, user name, home or business address, telephone numbers and email address.
  • Financial information such as your credit card or debit card number, bank account information, and your payment, service and purchase history.

Partners

  • Contact information such as your first and last name, home or business address, telephone numbers and email address; and
  • Driver’s license or government-issued identification to verify identity when visiting our offices.

Employment Applicants

  • Contact information such as your first and last name, home or business address, telephone numbers and email address;
  • Your current or past employment or educational information;
  • Relevant licenses and certifications; and
  • Other information that could reasonably be used to identify you personally.

For information about the Personal Information we collect about job applicants, employees and independent contractors, please see our Employee Privacy Notice.

Information Automatically Collected

Like many businesses, we and “Partners” who include third-party service providers, advertisers, advertising network and platforms, agencies, our online store partners (such as Shopify), fulfillment, distribution or other partners may automatically collect and/or store certain information when you visit or interact with the Sites or Services (“Usage Information”), including via cookies and other tracking technologies. This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Sites. Usage Information includes:

  • Your Internet Protocol (“IP”) address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier;
  • Your Device functionality (including browser, browser language, settings and behavior, operating system, hardware, mobile network information);
  • Referring and exit web pages and URLs;
  • The areas within the Sites that you visit and your activities there, including remembering you and your preferences;
  • Your Device location or other location information, including the zip code, state or country from which you accessed the Services;
  • Your Device characteristics;
  • Certain other Device data, including the time of day you visit our Sites or other information used to provide analytics or other usage information;
  • Information about your engagement with our emails; and
  • Statistical information about how both unregistered and registered users, collectively, use the Sites and Services. This aggregate information is derived from Personal Information but cannot be tied back to you or your web browser.

For location information, some of our Services include features based on users’ actual locations and may report on users’ current locations (“Location-Based Services”). If you use Location-Based Services, we collect and store information about your location at the time you use those Location-Based Services (in addition to some automatically collected geolocation data). This information comes from a variety of sources depending on the device you use to access the Services; for example, a mobile phone may report its GPS location at the time Location-Based Services are used.

If you do not wish for us or our service providers to collect and use location information, you may disable the location features on your device. Consult your device settings for instructions. Please note that if you disable such features, your ability to access certain features, Services, content, promotions, or products may be limited or disabled.

Information Collected from Third Parties

The Sites include functionality that allows interactions with your account on social media services or other third-party websites, plug-ins, integrations and applications. This functionality may involve the third-party website providing information to us. For example, through these interactions, we may have access to certain Personal Information in your profile, including your name, e-mail address, gender, birthday, location, account ID, user files such as photos and videos, your list of friends or connections, accounts you follow and/or who follow you, or your posts or “likes.” We may also provide links to allow third parties to process credit card and/or electronic payments for our online store or other applications. These third parties may retain any information used or provided in any such interaction and these parties are not subject to this Policy.

We may not control or have access to your communications through these third parties. For a description on how social media services and other third-party platforms, plug-ins, integrations or applications handle your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings. Please note that when you use third-party sites or services, you are using their services and not our Services, and they, not we, are responsible for their practices.

Information We Infer

We derive information or draw inferences about you based on information we collect about you. For example, based on your browsing or purchases, we may infer your gender, your interest in certain activities or brands, or information about your purchasing activities over time.

4. Use of Cookies and Other Tracking Technologies

We use various methods and technologies (“Tracking Technologies”) to store or collect Usage Information. Tracking Technologies may set, change, alter or modify settings or configurations on your Device. These tracking technologies allow us to collect information such as your device type, browser type, interactions with our Sites, geographic location, your web requests, the date and time of your web request, your IP address, the domain name of your Internet service provider and other data. If you can be identified from this information – for example by combination with other pieces of information – then we will treat this as Personal Information.

A few of the Tracking Technologies used on the Sites include, but are not limited to, the following (as well as future-developed tracking technologies or methods not listed here):

  • Cookies. A cookie is a file placed on a Device to identify your browser or to store information on your Device. Our Sites may use HTTP cookies, HTML5 cookies and other types of cookie technology to store information on local storage.
  • Pixels: A pixel is a small graphic file that allow us and third parties to monitor the use of the Sites and provide us with information based on your interaction with the Sites.
  • Web Beacons. A Web Beacon is a small tag (which may be invisible to you) that may be placed on pages and messages of our Sites.
  • Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Sites, such as the links you click on.
  • ETag, or entity tag. An Etag or entity tag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL.
  • Browser Fingerprinting. Browser fingerprinting allows collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data for purposes of identification.
  • Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).

Many browsers default to accepting cookies. You may be able to change this setting in your browser and you can also clear your cookies. If you do, you may lose some functionality of our Sites.

You can get more information about Cookies and Tracking Technologies, and instructions on how to opt out of cookies and certain tracking technologies, in our Cookie Policy.

5. Why We Collect Information

We use the information we collect about you in a variety of ways, including the following:

To Provide Our Services

We process certain Personal Information when you access or use our Services, including to:

  • Process your purchases of, or requests for, products and services;
  • Create and verify user accounts;
  • Facilitate the functionality of our Sites, including payment-related functionality; and
  • Customize experiences and personalization when you are on our Sites.

To Communicate with You

We process certain information to communicate with you in relation to your accounts, our Services, our marketing, and your requests, including to:

  • Communicate with you about orders, purchases, returns, Services, accounts, programs, campaigns, events, contests, and sweepstakes;
  • Respond to customer service inquiries and requests for information;
  • Respond to Partner inquiries;
  • Post your comments or statements on our Sites;
  • Send you personalized promotions, content, and special offers;
  • Communicate with you about our brands, products, events, or other promotional purposes;
  • Implement your communications preferences, such as sharing information with our business partners so that they may email you about their promotions, products and initiatives; and
  • Provide important product safety information and notice of product recalls.

For Improvement of Our Sites or Services

We want to ensure that our Sites and Services are continually improving and expanding so that we meet and exceed your needs and expectations. To do so, we process certain Personal Information, including to:

  • Maintain, improve, and analyze our Sites or Services; and
  • Detect, prevent, or investigate suspicious activity or fraud.

To Comply with Applicable Laws

We may be required to process certain Personal Information under certain laws and regulations, such as tax laws, as well as to:

  • Maintain appropriate records for internal administrative purposes; and
  • Comply with applicable legal and regulatory obligations, and respond to lawful governmental requests, as needed.

To Enforce our Terms, Agreements, or Policies

To maintain a safe, secure, and trusted environment for you when you use our Sites and Services, we use your Personal Information to ensure our terms, policies, and agreements with you and any third parties are enforced.

To Evaluate Your Application for Employment

We use your Personal Information to evaluate your application for employment or administer employment benefits.

With Your Consent

We process certain Personal Information to fulfill any other business or commercial purposes at your direction or with your consent.

6. When We Disclose Information

Service Providers

We share your Personal Information with our third-party service providers who provide services such as website hosting, payment processing, data analysis, information technology, customer service, email delivery, online advertising, auditing, event planning and other services.

Partners

We share your Personal Information with our Partners, affiliates and other third parties, such as companies with whom we have marketing or other relationships, for direct marketing purposes. In addition, we may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described in this Policy.

Third-Party Advertising

You may see certain ads on our Sites because we participate in advertising networks administered by third parties. These networks track your online activities over time and across third party websites and online services by collecting information through automated means, including through the use of the Tracking Technologies described above. They then use this information to show you advertisements that are tailored to your individual interests. The information they collect includes information about your visits to our Sites, such as the pages you viewed. This collection and ad targeting takes place on our Sites and on third-party websites that participate in the ad network. This process also helps us track the effectiveness of our communications and marketing efforts.

For more information about how targeted advertising works, visit the Network Advertising Initiative’s educational page here.

You can opt out of targeted advertising on certain platforms by visiting the following:

Other

To the extent permitted by law, certain Personal Information about you may be disclosed in the following situations:

  • To comply with a validly issued and enforceable subpoena or summons.
  • In conjunction with a prospective purchase, sale, or merger of all or part of our business, if we take appropriate precautions (for example, through a written confidentiality agreement) so the prospective purchaser or merger partner does not disclose information obtained in the course of the review.
  • As a part of any actual or threatened legal proceedings or alternative dispute resolution proceedings either initiated by or against us, provided we disclose only the information necessary to file, pursue, or defend against the lawsuit and take reasonable precautions to ensure that the information disclosed does not become a matter of public record.
  • To provide information to our Partners and nonaffiliated third parties who perform services or functions for us in conjunction with our services to you, but only if we have a contractual agreement with the other party that prohibits them from disclosing or using the information other than for the purposes for which it was disclosed.

Finally, we may aggregate, de-identify, and/or anonymize any information collected through the Sites or Services such that such information is no longer linked to your personally identifiable information. We may use and share this aggregated and anonymized information (non-Personal Information) for any purpose, including without limitation, for research and marketing purposes, and may also share such data with our affiliates and third parties, including advertisers, promotional partners and others.

7. Your Privacy Choices

Communications Preferences

We prefer to keep your Personal Information accurate and up to date. If you would like to change your contact information, please contact us using the information in the Contact Us section below. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records).

You can opt out of receiving emails or text messages from us at any time. To manage your email preferences with us, please click on the Unsubscribe link in any email you receive from us or contact us using the information in the Contact Us section below. Your choice will not affect our ability to share information in the other ways described in this Policy.

To opt out of text messages from us, text “STOP” to +1 (833) 996-2905 at any time.

Please note that certain of your Personal Information, such as your name or other identifying information, may remain in our database even after an unsubscribe or deletion request to service your account, maintain the integrity and historical record of our database and systems, or to comply with applicable laws and regulations.

Analytics

We use Google Analytics to help us understand how visitors use the Site. Read more about how Google uses your Personal Information here and opt-out of Google Analytics here.

Do Not Track

Do Not Track (“DNT”) is a web browser setting that requests that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and other web services you encounter while browsing to stop tracking your activity. Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals), but there is no universally agreed upon standard for what an organization should do when it detects a DNT signal. Currently, we do not monitor or take any action with respect to these signals or other mechanisms. You can learn more about Do Not Track here.

8. Children’s Privacy

Our Site is not intended for use by users under the age of majority, typically that means that our Site is intended for an audience that is 16 years of age or older. We do not request, or knowingly collect, any Personal Information from children under the age of 16. Minors under the age of 16 (but older than 12) may use the Sites only under the supervision of a parent or guardian who agrees to be bound by our Terms of Use. If you are the parent or guardian of a child under 16 who you believe has provided her or his information to us, please contact us using the information in the Contact Us section below to request the deletion of that information.

9. Visitors to the Sites Outside of the United States

Our Sites are operated in the United States. If you are visiting the Sites from a location outside of the U.S., your connection will be through and to servers located in the U.S. All information you receive from the Sites will be created on servers located in the U.S., and all information you provide will be maintained on web servers and systems located within the U.S. The data protection laws in the U.S. may differ from those of the country in which you are located, and your information may be subject to access requests from governments, courts, or law enforcement in the U.S. according to laws of the United States. By using the Sites or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information in the U.S. and in other countries, as set forth in this Policy.

10. Links

For your convenience, the Sites and this Policy may contain links to other websites. We are not responsible for the privacy practices, advertising, products, services, or the content of such other websites. None of the links on the Sites should be deemed to imply that Fulwell endorses or has any affiliation with the links.

11. Security

We incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission, or electronic storage of information can be guaranteed 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit to or from the Sites, and you provide us with your information at your own risk.

12. Retention of Personal Information

We will retain your Personal Information only for as long as is necessary for the purposes set out in this Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

All information you provide to us is stored on our secure servers or those of our third-party data storage providers.

When deciding how long to keep your information, we consider:

  • How long we have had a relationship with you or provided our Services to you;
  • Whether we are subject to any legal obligations (e.g., any laws that require us to keep transaction records for a certain period before we can delete them);
  • Whether we have taken any legal positions (e.g., in connection with any statutes of limitation).

Rather than delete your Personal Information, we might de-identify it by removing identifying details.

13. Your California Privacy Rights

This section of the Policy applies solely to California residents. We adopt this Section to comply with the California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”). Any terms defined in the CCPA or CPRA have the same meaning when used in this Section.

California residents have the following rights:

  • To know the categories of Personal Information being collected about you, the purposes for which the categories of information are collected or used, and whether that information is sold or shared;
  • To know the length of time we intend to retain each category of Personal Information;
  • To know whether your Personal Information is sold or disclosed and to whom;
  • To access your Personal Information;
  • To delete the information you have provided to us, with certain exceptions;
  • To correct your Personal Information;
  • To opt out of the sale of Personal Information;
  • To know if Sensitive Personal Information (“SPI”) is being collected about you, the categories of SPI being collected, the purposes for which the categories of SPI are collected or used, and whether the SPI is sold or shared;
  • To limit the use of your SPI if it is used for cross-contextual behavioral advertising or for the purposes of inferring characteristics about you; and
  • Not to be discriminated against, even if you exercise your privacy rights.

Request for Information, Correction, or Deletion

California residents have the right to request, under certain circumstances, that a business that collects Personal Information disclose the information listed below for the preceding 12 months:

  • The categories of Personal Information collected about you;
  • The categories of sources from which the Personal Information is collected;
  • The business or commercial purpose for collecting, selling or sharing Personal Information;
  • The categories of third parties to whom the business discloses Personal Information; and
  • The specific pieces of Personal Information collected about you.

Please note that if we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.

You can also request that we correct or delete your Personal Information. There may be certain exceptions to our obligation to correct or delete your Personal Information such as if you have an existing account or transaction with us or if we have a legitimate business reason to keep your information.

Personal Information Collected

We have collected the following categories of Personal Information from consumers within the last twelve (12) months:

Category of Personal Information Examples of this Category Sources of Personal Information Business Purpose for Collection
Identifiers Real name, alias, postal address, unique personal identifier, online identifier, Internal Protocol address, email address, account name or other similar identifiers.
  • You
  • Automatically
  • Third Parties
  • To provide, market and improve our products and Services
  • To provide information you requested
  • To identify potential customers
  • To verify identity
  • To prevent fraud
  • To comply with law
Personal information described in California Civ. Code § 1798.80(e) Name, signature, physical characteristics or description, address, telephone number, bank account number, credit card number, debit card number, or any other financial information.
  • You
  • Automatically
  • Third Parties
  • To provide, market and improve our products and Services
  • To provide information you requested
  • To identify potential customers
  • To verify identity
  • To prevent fraud
  • To comply with law
Characteristics of protected classifications under California or federal law Age, sex (including gender, gender identity, gender expression, political activities or affiliations. N/A N/A
Commercial information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • You
  • Automatically
  • To provide, market and improve our products and Services
  • To provide information you requested
  • To identify potential customers
  • To verify identity
  • To prevent fraud
  • To comply with law
Internet or other electronic network activity information Browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement. Automatically
  • To provide, market and improve our products and Services
  • To provide information you requested
  • To identify potential customers
  • To verify identity
  • To prevent fraud
  • To comply with law
Geolocation data Physical location and/or movements. N/A N/A
Sensory data Audio, electronic, visual, thermal, olfactory, or similar information.
  • You
  • Automatically
  • To provide, market and improve our products and Services
  • To provide information you requested
  • To identify potential customers
  • To verify identity
  • To prevent fraud
  • To comply with law
Professional or employment related information Current or past job history or performance evaluations. For Employment Applicants, please see our Employee Privacy Notice N/A N/A
Non-public education information (per the Family Educational Rights and Privacy Act – 20 U.S.C. § 1232g, 34 CFR Part 99) Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. N/A N/A
Inferences drawn from other Personal Information Information used to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
  • You
  • Automatically
  • Third Parties
  • To provide, market and improve our products and Services
  • To provide information you requested
  • To identify potential customers
  • To verify identity
  • To prevent fraud
  • To comply with law
Sensitive Personal Information Account log-in, debit, or credit card number in combination with password or PIN, precise geolocation (less than 1850 sf radius), N/A N/A

Personal Information Sold or Shared

Category of Personal Information Recipient Categories Purpose for Sale/Sharing
Identifiers Advertising, marketing, and analytics providers Marketing and analytics
Commercial information Advertising, marketing, and analytics providers Marketing and analytics
Internet or other electronic network activity information Advertising, marketing, and analytics providers Marketing and analytics
Inferences drawn from other Personal Information Advertising, marketing, and analytics providers Marketing and analytics

Personal Information Disclosed for Business Purposes

Category of Personal Information Recipient Categories Business Purpose for Disclosure
Identifiers Service Providers
  • Helping to ensure the security and integrity of Personal Information
  • Debugging to identify and repair errors
  • Performing services on behalf of the business
  • Internal research for technological development and demonstration
  • Activities to verify or maintain the quality of, improve, upgrade, and/or enhance our services
Commercial information Service Providers
  • Helping to ensure the security and integrity of Personal Information
  • Debugging to identify and repair errors
  • Performing services on behalf of the business
  • Internal research for technological development and demonstration
  • Activities to verify or maintain the quality of, improve, upgrade, and/or enhance our services
Internet or other electronic network activity information Service Providers
  • Helping to ensure the security and integrity of Personal Information
  • Debugging to identify and repair errors
  • Performing services on behalf of the business
  • Internal research for technological development and demonstration
  • Activities to verify or maintain the quality of, improve, upgrade, and/or enhance our services
Inferences drawn from other Personal Information Service Providers
  • Helping to ensure the security and integrity of Personal Information
  • Debugging to identify and repair errors
  • Performing services on behalf of the business
  • Internal research for technological development and demonstration
  • Activities to verify or maintain the quality of, improve, upgrade, and/or enhance our services

14. Your Privacy Rights under Other US State Laws

If you live in certain other U.S. states, such as Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, Nevada, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have rights under applicable privacy laws once those laws have become effective (together, the “Relevant State Privacy Laws”):

Based on the applicable law in the state where you live, you may have the following rights with respect to your Personal Information, upon a verified request:

  • To confirm whether a controller is processing your personal data and to access such personal data;
  • To correct inaccuracies in your personal data;
  • To delete your personal data;
  • To obtain a copy of your personal data that you previously provided to us in a portable, and if technically feasible, readily usable format, if processing is carried out by automated means;
  • To opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

To exercise these rights, you or your authorized agent may make a request to confirm, access, correct, delete, obtain a copy, or opt out of the processing of your personal data for targeting advertising, sale, or profiling by contacting us using the information in the Contact Us section below.

If you use an authorized agent to submit your request, we may require proof of the written authorization you have given. We also may require you to confirm your identity and your residency in order to obtain the information. For emails, please include “Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a resident of Colorado, Connecticut or Virginia. We will process your request within 45 days or let you know if we need additional time or cannot process your request.

Right to Opt Out Under Applicable State Laws

Residents of certain jurisdictions may have the right to opt out of the sale of their Personal Information and targeted advertising. To exercise your right, please click on email privacy@fulwell.com.

California residents may have additional rights, as shown in the Your California Privacy Rights section above.

Opt-Out Preference Signals

Some browsers and browser extensions support opt-out preference signals such as the Global Privacy Control (“GPC”) that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales. GPC is a web browser-level setting, maintained by either a browser or a browser extension, that a user or privacy-focused technology can set. In certain regions, when we detect such a signal, we will make reasonable efforts to respect your choices as required by applicable law.

Appeals of Our Decisions

In some states, you may appeal to us if we refuse to take action on your exercise of certain choices described above. To appeal such a refusal, please contact us using the information in the Contact Us section below with the subject line “Appeal of Refusal to Take Action on Privacy Request” and provide the relevant information in the email.

15. Your Rights Under the General Data Protection Regulation

Although we do not direct our activities at visitors outside of the United States, we recognize that in this global economy, certain visitors to our website or users of our Services may fall under the GDPR. This section of the Policy applies if you are a data subject who is a citizen of or located within the European Economic Area (“EEA”). We adopt this section to comply with European privacy laws, including the General Data Protection Regulation (“GDPR”). Any terms defined in the GDPR have the same meaning when used in this section.

Under applicable law, we are considered the “data controller” of the Personal Information we handle under this Policy. In other words, we are responsible for deciding how to collect, use and disclose this information, subject to applicable law.

We want to ensure that the Personal Information we possess is always accurate and therefore we encourage you to update your information in case any changes have occurred. We have listed below the rights that you may be able to exercise in respect of the processing of your Personal Information, subject to applicable law. We take every reasonable step to ensure that the Personal Information that we process is limited to the Personal Information that are reasonably required in connection with the purposes set out in this Policy.

If you are a citizen of or located within the EEA, you have certain data protection rights. These rights include:

  • The right to access, update or delete the Personal Information we have collected from you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Information.
  • The right of restriction. You have the right to request that we restrict the processing of your Personal Information.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your Personal Information.

Legal Basis for Processing Personal Information

We rely on the following legal bases for processing your Personal Information:

  • Contract: To conclude or perform a contract with you; for example:
    • To manage and fulfill orders, facilitate delivery, and to provide other Services;
    • To manage our accounts and records;
    • To handle your inquiries and requests;
    • When you apply for employment through our Sites, processing of your contact details and data about your employment history and education (as needed to evaluate your job application, to conduct job interviews, and as is otherwise needed for recruitment) is necessary to respond to your request to process your application for employment. If you do not provide this data, we will not be able to process the application that you send through our Sites.
  • Legitimate Interests: When we process your Personal Information for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your Personal Information for activities where our interests are overridden by the impact on you unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests, as further described below. Examples of legitimate interests include:
    • To respond to your customer service inquiries and requests for information;
    • To maintain, improve, and analyze our Sites, ads, and Services we offer;
    • To conduct marketing activities;
    • To detect, prevent, or investigate security breaches or fraud; and
    • To facilitate the functionality of our Sites;
  • Legal Compliance: To comply with our legal obligations; for example:
    • To maintain appropriate records for internal administrative purposes and as required by applicable law, and
    • To provide important product safety information and notice of product recalls
  • Consent: We will send you information by email on our Services or other promotions only with your consent or if you otherwise opt-in to receiving those communications. If you do not provide us with your consent to the processing of your Personal Information for this purpose, we will not send you this information. You have the right to withdraw your consent at any time as described below.

How to Exercise Your Rights Under the GDPR

If applicable, you may exercise any of your rights under the GDPR by submitting a verifiable data subject request to us by using the contact details below. You may make a request related to your Personal Information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of the EEA by including your country of citizenship or residence in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in the EEA to obtain the information. We will respond to your request within 30 days or let you know if we need additional time.

Please note that we will ask you to verify your identity before responding to such requests, and we may deny your request if we are unable to verify your identity or authority to make the request.

Should you wish to raise a concern about our use of your data (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first by contacting us using the information in the Contact Us section below.

16. Your Rights Under the UK GDPR

If you are based in the United Kingdom, the following provisions also apply:

If we share your personal data within Fulwell or with third parties located outside the United Kingdom, we take steps to ensure that appropriate safeguards are in place to guarantee the continued protection of your personal data, such as by entering into the international data transfer addendum to the European Commission’s Standard Contractual Clauses, adopted by the UK Government under section 119A of the Data Protection Act 2018.

You have the same data subject rights as those for the EU listed above, except that references to the "GDPR" should be read as references to the "UK GDPR" and complaints should be filed with the UK supervisory authority, the Information Commissioner’s Office.

17. Your Canada Privacy Rights

Canadian laws provide specific privacy rights to our Canadian customers. If you are a resident of Canada, this section applies in addition to all other applicable rights and information contained in this Policy.

Where applicable, we follow applicable Canadian federal and provincial privacy laws (“Canadian Privacy Law”), including:

  • The Personal Information Protection and Electronic Documents Act (PIPEDA)
  • Alberta’s Personal Information Protection Act (Alberta PIPA)
  • British Columbia’s Personal Information Protection Act (BC PIPA)
  • Québec's Act respecting the protection of Personal Information in the private sector (Québec Act)

Consent

In most cases, we rely on implied consent to collect, use, or disclose your Personal Information. In some circumstances, including those involving sensitive Personal Information, we obtain express consent. Where you have provided your consent to the collection, use, and transfer of your Personal Information (whether orally, in writing, or electronically), you may have the legal right to withdraw your consent under certain circumstances. In addition to the methods described above with respect to your privacy choices, you may withdraw your consent by submitting a request using the information in the “Contacting Us” section below. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time of your request to help you with your decision.

Use of Your Personal Information

We will not collect, use, or disclose Personal Information except for the identified purposes identified above (see Disclosure of Your Information), unless we have received additional consent or the processing is authorized without consent. Where we engage service providers who utilize the Personal Information we provide to them, those relationships are governed by a written agreement regarding the confidentiality of your information.

Canadian Access and Challenge Rights

Canadian Privacy Law provides the right to receive information about the existence, use, and disclosure of your Personal Information and to be provided access to that information. You may also challenge the accuracy and completeness of your Personal Information and have it amended as appropriate. Depending on the nature of the challenged information, amendment may involve correction, deletion, or addition of information.

Exercising Your Canadian Privacy Rights

If you have an account with us, you may view and update your account information directly by logging into your account. To submit a request for access to information not contained within your account, or to challenge the accuracy or completeness of your Personal Information, you may also submit a written request using the information in the Contact Us section below. When submitting a request, we may require you to confirm your identity and your residency to obtain the information. For emails, please include “Canadian Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a Canadian resident, and provide your province of residence. We will begin processing your request once you have completed the verification process and will respond within the timeframe required by law.

If we cannot substantively respond to your request in a timely manner, we will notify you and state the reason for the delay. Under certain circumstances, we may not be able to fulfill your request, such as when doing so would interfere with our regulatory or legal obligations, where we cannot verify your identity, or if your request involves disproportionate cost or effort. However, we will respond to your request within a reasonable time, as required by law, and provide an explanation.

Additional information about how to exercise your rights under Canadian Privacy Law can be found here.

Office of the Privacy Commissioner of Canada – Website
Phone: 1-800-282-1376

Office of the Information and Privacy Commissioner of Alberta – Website
Phone: 1-888-878-4044
Edmonton office: (780) 422-6860
Calgary office: (403) 297-2728

Office of the Information and Privacy Commissioner of British Columbia – Website
Vancouver: (604) 660-2421
Elsewhere in BC: (800) 663-7867

Commission d'accès à l'information du Quebec – Website
Phone: 1-888-528-7741

18. Changes to This Privacy Policy

We may change this Privacy Policy at any time. We will post all changes to this Policy on this page and will indicate at the top of the page the modified notice's effective date. We therefore encourage you to refer to this page on an ongoing basis so that you are aware of our current privacy policy. If required by applicable law, we will notify you of the changes.

By continuing to use the Sites or Services or providing us with information when a replacement Policy is uploaded, you agree that you will be deemed to have agreed to be bound by the Privacy Policy as changed.

19. Contact Us

If you have any questions or suggestions regarding this Policy, please contact us as follows:

Fulwell Entertainment, LLC
1500 N. El Centro Avenue, Suite 200
Los Angeles, California 90028
Email: privacy@fulwell.com